The MLI streamlines the implementation of BEPS (Base Erosion and Profit Shifting) measures, and this new annex provides the specific effective dates for withholding taxes and other taxes for each treaty.

RF Report

The French tax authorities (FTA) published a new annex BOI-ANNX-000511 on 29 April 2026 listing 68 tax treaties concluded by France that have been modified by the OECD’s Multilateral Instrument (MLI), under the OECD Base Erosion and Profit Shifting (BEPS) framework.

The MLI, in force for France since 1 July 2019, allows BEPS-related tax treaty measures to be incorporated into existing double tax treaties.

The annex sets out, for each covered tax agreement, the effective dates for withholding taxes and other taxes, along with references to consolidated treaty texts.

Application dates vary by jurisdiction, with early application in 2019 for several countries and phased implementation continuing into 2026 for certain treaties. Some agreements have also been amended through most-favoured-nation clauses.

There are 68 countries (jurisdictions) in the list:

Europe Americas Africa Asia & Middle East
Albania Argentina Cameroon Australia
Andorra Canada Egypt Bahrain
Austria Chile Kenya China
Belgium Mexico South Africa India
Bulgaria Panama Tunisia Indonesia
Croatia US Senegal Israel
Cyprus Brazil Ivory Coast Japan
Czech Republic Jamaica Malaysia
Finland Russia Mongolia
Germany Colombia New Zealand
Hungary Peru Oman
Iceland Uruguay Pakistan
Ireland Venezuela Qatar
Italy Saudi Arabia
Latvia Singapore
Lithuania South Korea
Luxembourg Thailand
Malta UAE
Netherlands Vietnam
Poland Hong Kong SAR
Portugal
Romania
Slovakia
Slovenia
Spain
Ukraine
UK

The FTA said the annex is intended to provide a consolidated administrative reference on the application timelines of MLI-modified treaties, including separate effective dates for withholding taxes and other taxes, as well as access to consolidated treaty versions.